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#2191725 - 09/05/18 10:09 PM Disclosure of Cutoff Times
TeamComply Offline
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Where are various cutoff times typically disclosed? For example, cutoffs for ATM deposits, Mobile Deposits, Electronic Transfers, telephone transfers, external transfers? Are these disclosed to customers in various disclosures or all in one? Thanks!

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Deposits and Payments
#2191734 - 09/06/18 01:04 PM Re: Disclosure of Cutoff Times TeamComply
HappyGilmore Offline
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Pulling people out of the ditc...
ours are all listed in our deposit agreement, given at time account is opened and made available when periodically updated
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#2191736 - 09/06/18 01:20 PM Re: Disclosure of Cutoff Times HappyGilmore
TeamComply Offline
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Thanks for your reply. Do you list any cutoff times within your Reg. CC disclosure?

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#2191742 - 09/06/18 01:35 PM Re: Disclosure of Cutoff Times TeamComply
rlcarey Offline
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Galveston, TX
Typically only check deposits subject to the act. I am not sure why you would include information on on-line banking transfers, for example, in your Funds Availability disclosure.
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#2191917 - 09/07/18 02:35 PM Re: Disclosure of Cutoff Times rlcarey
TeamComply Offline
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Appreciate your response. What about an ATM deposit cutoff time? Would it be acceptable to include it in our Reg. CC disclosure?

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#2191995 - 09/07/18 09:29 PM Re: Disclosure of Cutoff Times TeamComply
Andy_Z Offline
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https://www.bankersonline.com/regulations/12-229-019

Yes. And where permissible I would list an item once and refer all other disclosures of the same thing to that one document so that changes need be made only in one place, rather than multiples.
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#2192026 - 09/10/18 12:58 PM Re: Disclosure of Cutoff Times rlcarey
HappyGilmore Offline
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Pulling people out of the ditc...
Originally Posted By rlcarey
Typically only check deposits subject to the act. I am not sure why you would include information on on-line banking transfers, for example, in your Funds Availability disclosure.


if your daily cut off is anything transferred before X PM is credited same day and anything after is credited next day is one reason. Of course, you can also include on the OLB transfer screen the same information, so likely a choice by a bank depending how they want to do it.
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